Ibrahim Keita - Page 9

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          amount, we are generally permitted to estimate the deductible               
          amount.  Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir.               
          1930).  To apply the Cohan rule, the Court must have a reasonable           
          basis upon which an estimate can be made.  Vanicek v.                       
          Commissioner, 85 T.C. 731, 742-743 (1985).  Without such a basis,           
          any allowance would amount to unguided largesse.  Williams v.               
          United States, 245 F.2d 559, 560 (5th Cir. 1957).  However, the             
          strict rules of substantiation that apply to certain business               
          deductions described in section 274(d) supersede the rule in                
          Cohan v. Commissioner, supra at 544.  Sanford v. Commissioner, 50           
          T.C. 823, 827-828 (1968), affd. per curiam 412 F.2d 201 (2d Cir.            
          1969); Keating v. Commissioner, T.C. Memo. 1995-101; Jeffers v.             
          Commissioner, T.C. Memo. 1986-285; sec. 1.274-5T(a)(4), Temporary           
          Income Tax Regs., 50 Fed. Reg. 46014 (Nov. 6, 1985).                        
               Petitioner did not provide any receipts or any other                   
          evidence to establish when the computers, monitors, and fax                 
          machine were purchased, or the cost of the items.  Petitioner               
          testified that the amount he claimed on his Schedule C for the              
          computers and peripheral equipment was “a little over-inflated”             
          and that one of the computers was not even purchased in the tax             
          year in issue.  There is insufficient evidence to establish that            
          these items were purchased during the year in issue, or to                  
          substantiate the cost.  Accordingly, petitioner is not entitled             
          to a deduction for his computers, monitors, and fax machine.                

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